Our Tax Group includes lawyers with exceptional credentials and reputations, many with government experience, who advise multinational corporations, financial institutions, sovereign wealth funds, sports teams and leagues, and others on their most important and sensitive tax matters. These matters include the successful resolution of domestic and international tax controversies; inbound and outbound investments; mergers, acquisitions and dispositions; and the development, documentation, and defense of transfer pricing policies.
Covington’s tax controversy experience includes very large case audits; advance pricing agreements; and administrative appeals and litigation involving a broad spectrum of subject matter areas, including transfer pricing, foreign and research tax credits, accounting methods and periods, the treatment of corporate reorganizations and restructurings, the treatment of items under the consolidated return regulations, allocations under Section 861, partnership issues, allowance of losses on subsidiary stock, economic substance, and Subpart F inclusions. We understand that resolution of tax controversies requires creativity and a complete understanding of the impact of the controversy and potential resolutions on our clients.
Covington’s international tax practice first seeks to understand its clients goals and business operations. Working in close collaboration with our clients’ tax professionals, we employ both standard and creatively tailored planning to achieve sustainable tax minimization. Our experience includes developing and modifying trading structures, cash flow strategies and repatriation, advising on transfer pricing methods, internal restructurings, overall effective rate reduction, and post-acquisition integration. To address tax issues involving multiple jurisdictions, we rely on our own experience and on our network of correspondent firms (ordinarily one of the top three tax advisory firms in each country) or our clients’ regular foreign advisors.
Covington’s practice in the financial products area spans a broad range, encompassing domestic and international transactions, exchange-traded and over-the-counter products, hedging strategies, and more. We regularly advise clients on tax issues raised by new financial products, such as credit derivatives, structured debt, and exotic options. Our clients include US and foreign hedge funds, CDO sponsors, mutual funds, banks, pension trusts, corporations, and wealthy individuals.
Covington’s tax lawyers play an integral part in the firm’s transactions practice and regularly counsel clients on major corporate and partnership transactions. Our expertise includes advising clients on various acquisition structures in public and private mergers and acquisitions, spin-offs and distributions, tax efficient capitalization of new and existing subsidiaries, and joint venture and fund formation. In addition, we regularly advise clients in the renewable energy sector concerning various federal incentives that may apply to their transactions, including production and investment tax credits and grants.
Members of our tax group regularly represent clients and the public interest before the Treasury Department, before the National Office of the IRS, and in legislative matters, and are well known to high-level government policy makers. Members of our group with government experience include William M. Paul, former Deputy Tax Legislative Counsel in the Office of Tax Policy at the Treasury Department; Roderick DeArment, U.S. Senate Committee on Finance, Chief Counsel and Staff Director; Dirk J.J. Suringa, an Attorney Advisor in the office of International Tax Counsel; Scott D. Feldstein, Assistant Branch Chief in the Corporate Office of Assistant Chief Counsel, Interpretative Division; and Robert Culbertson, Associate Chief Counsel (International) for the Internal Revenue Service.
Covington’s tax lawyers are intimately familiar with every aspect of the sports industry, from sponsorship and broadcast agreements to player signing bonuses to franchise acquisitions. We combine our deep and broad knowledge of the business of sports with our technical expertise in tax law. Our clients include leagues and teams; corporations, partnerships, and individuals; and domestic and foreign entities.
Representative tax clients include Armani SPA, Bacardi Ltd, Bank of America, Bristol-Myers Squibb, Brown Brothers Harriman, Bunge Ltd, GE, Hitachi, IBM, Eastman Kodak, The Interpublic Group of Companies, Investment Company Institute, Major League Baseball, the National Basketball Association, the National Football League, the National Hockey League, Natixis, Norfolk Southern, PepsiCo, SandRidge Energy, Sotheby’s, Sun Financial, The Timken Company, Terex, United Technologies Corporation, Vivendi, and Weyerhaeuser.
Accolades
Our tax partners have received individual honors and hold leadership positions in a number of professional organization.
- Chambers USA 2011 ranked Covington among outstanding nationwide tax practices and again as a leading DC tax practice, and recognized William Chip, Robert Culbertson, Daniel Luchsinger, William Paul, Dirk Suringa, and Reeves Westbrook as top tax practitioners.
- Roderick DeArment, William Paul, and Reeves Westbrook were listed in the 2008-2011 editions of Best Lawyers in America.
- William Paul is chair-elect of the Tax Section of the American Bar Association, a fellow in the American College of Tax Counsel, and a member of the American Law Institute. Mr. Paul was listed as a top lawyer in the 2009 edition of the Washingtonian, and named a leading tax lawyer in International Who's Who of Tax Lawyers.
- William Chip serves on the Tax Committee of the OECD’s Business and Industry Advisory Committee and chairs the following committees: Tax Treaty Subcommittee of the American Bar Association’s Tax Section’s Committee on Foreign Activities of US Taxpayers and Transfer Pricing Subcommittee of the US Council for International Business’s Tax Committee.
- Reeves Westbrook chairs the Transfer Pricing and Litigation Subcommittee of the International Bar Association’s Tax Committee, and was named a leading tax lawyer in International Who's Who of Tax Lawyers.
- Robert Culbertson, former Associate Chief Counsel (International) for the Internal Revenue Service (IRS), has more than 25 years of international taxation experience, including 13 years in the government. He participated in many significant developments in US international taxation, including the revision of the US transfer pricing regulations, the parallel development of new OECD guidelines, and the development of regulations relating to foreign tax credits, subpart F rules, outbound transfers, and conduits.
- Daniel Luchsinger is an adjunct professor of law at the Georgetown University Law Center.
- Dirk Suringa is a member of the executive committee of the International Fiscal Association, USA Branch and also of the Tax Management Advisory Board, U.S. International.
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